STATUS REPORT Joint Status Report by USA as to Te Dora Brown, Christopher Scott — USA v. Brown, et al. (Dkt. 48)

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:23-cr-00097 · Doc. 48 · 2023-12-05 · Docket on CourtListener

Summary

A joint status report filed December 5, 2023 as Doc. 48 in United States v. Te Dora Brown and Christopher Scott, No. 1:23-cr-00097, before Judge Elaine E. Bucklo in the U.S. District Court for the Northern District of Illinois. The report states that on February 15, 2023 a grand jury indictment charged Brown with 13 counts and Scott with 9 counts of wire fraud under 18 U.S.C. § 1343, that the defendants self-surrendered on March 1, 2023, and that both are on bond. It says the government has produced all discovery and, as to Brown, requested reciprocal discovery on November 8, 2023; as to Scott, the government is drafting a plea agreement at the defense's request. The parties ask for a further status report in approximately 90 days and for time to be excluded under 18 U.S.C. § 3161(h).

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UNITED STATES DISTRICT COURT 
 
NORTHERN DISTRICT OF ILLINOIS 
 
EASTERN DIVISION 
 
UNITED STATES OF AMERICA 
 
 
v. 
 
TE DORA BROWN, and 
CHRISTOPHER SCOTT 
 
Case No. 23 CR 97 
 
Judge Elaine E. Bucklo 
 
JOINT STATUS REPORT 
 
The UNITED STATES OF AMERICA, by MORRIS PASQUAL, Acting United 
States Attorney for the Northern District of Illinois, Victor P. Henderson, counsel for 
defendant Te Dora Brown, and Joshua B. Adams, counsel for defendant Christopher 
Scott, hereby provide this joint status report to the Court: 
On February 15, 2023, the grand jury returned an indictment charging 
defendant Brown with 13 counts of wire fraud, and defendant Scott with 9 counts of 
wire fraud, all in violation of 18 U.S.C. § 1343. (R.1). Defendants self-surrendered on 
March 1, 2023 and the Court held initial appearances and arraignments for the 
defendants on that day. (R.8, 9). Defendants are currently on bond. (R.13, 14, 21). 
The government has produced all discovery to defense counsel and obtained a 
protective order for that discovery (R.27). 
As to defendant Te Dora Brown, counsel met and conferred in September 2023. 
During that meeting, defense counsel made the government aware of certain 
additional Rule 16 discovery in the case in defense counsel’s possession. The 
government made a formal request for reciprocal discovery on November 8, 2023. As 
Case: 1:23-cr-00097 Document #: 48 Filed: 12/05/23 Page 1 of 3 PageID #:150

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of the time of this joint status report, the government is still awaiting the same. 
As to defendant Christopher Scott, the government is currently drafting a plea 
agreement at the defense’s request, and plans to tender the same before the end of 
the year. 
 Accordingly, the parties respectfully request that the Court set a deadline for 
a status report in approximately 90 days, on or about Friday, March 1, 2023, or on a 
date at the Court’s discretion, and move the Court to exclude time through the date 
of the next status report pursuant to 18 U.S.C. § 3161(h) in the interests of justice 
and to allow time for continued negotiations between the parties. 
 
Date: December 4, 2023 
 
Respectfully submitted, 
 
MORRIS PASQUAL 
Acting United States Attorney 
 
By: 
/s/ Alejandro G. Ortega  
ALEJANDRO G. ORTEGA 
Assistant U.S. Attorney 
219 South Dearborn Street 
5th Floor 
Chicago, IL 60604 
(312) 353-4129 
 
/s/ Victor P. Henderson      
VICTOR P. HENDERSON 
Henderson Parks, LLC 
140 South Dearborn Street 
Suite 1020 
Chicago, IL 60603 
(312) 262-2900 
Case: 1:23-cr-00097 Document #: 48 Filed: 12/05/23 Page 2 of 3 PageID #:151

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/s/ Joshua B. Adams      
JOSHUA B. ADAMS 
Law Offices of Joshua B. Adams, 
PC 
900 W. Jackson Blvd., Suite 7 
East 
Suite 1020 
Chicago, IL 60607 
(312) 566-9173 
 
 
 
Case: 1:23-cr-00097 Document #: 48 Filed: 12/05/23 Page 3 of 3 PageID #:152

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